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5 r«7 3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY VttMr/ WASHINGTON, DC 20460 OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION May 16, 2012 •*— Pioneer Americas, LLC, D/B/A Olin Chlor Alkali Products c/o Cristina Griffin, Agent Delta Analytical Corp. 12510 Prosperity Drive, Suite 160 Silver Spring, MD 20904 Subject: Bacti-Chlor EPA Registration Number: 37982-38 Letter Date: April 23, 2012 EPA Receipt Date: April 25, 2012 Dear Ms. Griffin: This acknowledges receipt of the following notification, submitted in accordance with the provisions of PR Notice 98-10 under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) section 3(c) 9. Proposed amendments: Delete mentions of Bill of Lading. Change "Net Wt: [See Bill of Lading]" to "Net Contents: _ Gallons". Adding reader's notes to bottom of page 2 (Non Ag Uses). General comments: Based on a review of the material submitted, the notification as referenced above is acceptable. A copy of the notification has been added to the product's file. Should you have any questions or comments concerning this letter, please contact Eliza Blair via email at blair. eliza(a),epa.gov or by telephone at (703) 308-7279. lager(32) Regulatory Management Branch II /Antimicrobials Division (751 OP)
Transcript
Page 1: US EPA, Pesticide Product Label, BACTI-CHLOR, 05/16/2012 · 5/16/2012  · Products / Bacti-Chlor 2. EPA Product Manager Monisha Harris PM#32 3. Proposed Classification D None D Restricted

5 r«7 3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCYVttMr/ WASHINGTON, DC 20460

OFFICE OF CHEMICAL SAFETYAND POLLUTION PREVENTION

May 16, 2012•*—

Pioneer Americas, LLC, D/B/A Olin Chlor Alkali Productsc/o Cristina Griffin, AgentDelta Analytical Corp.12510 Prosperity Drive, Suite 160Silver Spring, MD 20904

Subject: Bacti-ChlorEPA Registration Number: 37982-38Letter Date: April 23, 2012EPA Receipt Date: April 25, 2012

Dear Ms. Griffin:

This acknowledges receipt of the following notification, submitted in accordance with the provisionsof PR Notice 98-10 under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) section3(c) 9.

Proposed amendments:

• Delete mentions of Bill of Lading.• Change "Net Wt: [See Bill of Lading]" to "Net Contents: _ Gallons".• Adding reader's notes to bottom of page 2 (Non Ag Uses).

General comments:

Based on a review of the material submitted, the notification as referenced above isacceptable. A copy of the notification has been added to the product's file.

Should you have any questions or comments concerning this letter, please contact Eliza Blairvia email at blair. eliza(a),epa.gov or by telephone at (703) 308-7279.

lager(32)Regulatory Management Branch II

/Antimicrobials Division (751 OP)

Page 2: US EPA, Pesticide Product Label, BACTI-CHLOR, 05/16/2012 · 5/16/2012  · Products / Bacti-Chlor 2. EPA Product Manager Monisha Harris PM#32 3. Proposed Classification D None D Restricted

Please read instructions on reverse before completing Form Approve IB No. 2070-0060.

EPAUnited States

Environmental Protection AgencyWashington, DC 20460

D RegistrationD AmendmentX Other

OPP Identifier Number

NOTIFApplication for Pesticide - Section I

1. Company/Product Number 37982-38

4. Company/Product (Name)

Pioneer Americas, LLC, D/B/A Olin Chlor AlkaliProducts / Bacti-Chlor

2. EPA Product Manager

Monisha Harris

PM#32

3. Proposed Classification

D None D Restricted

5. Name and Address of Applicant (Include ZIP Code)

Pioneer Americas, LLC, D/B/A Olin Chlor AlkaliProducts c/o Delta Analytical Corp.12510 Prosperity Drive, Suite 160Silver Spring, MD 20904 Check if this is a new address

6. Expedited Review. In accordance with FIFRA Section 3(c)(3)(b)(i), my productis similar or identical in composition and labeling to:

EPA Reg. No..

Product Name

Section - II

D Amendment - Explain belowD Resubmission in response to Agency letter dated_

X Notification - Explain below.

D Final printed labels in response to Agency letter dated_D "Me Too" Application.D Other - explain below.

Explanation: Use additional page(s) if necessary. (For section I and Section II.)

Notification under PR Notice 98-10 to add non pesticidal language and make minor label changes.

This notification is consistent with the provisions of PR Notice 98-10 and EPA regulations at 40 CFR 152,46, and no other changes have been made to thelabeling or the confidential statement of formula of this product. I understand that it is a violation of 18 U.S.C. Sec. 1001 to willfully make any falsestatement to EPA. I further understand that if this notification is not consistent with the terms of PR Notice 98-10 and 40 CFR 152.46, this product may bein violation of FIFRA and I may be subject to enforcement action and penalties under sections 12 and 14 of FIFRA.

Section - III

1. Material this Product will be Packaged in:

Child-Resistant PackagingD Yes*DNo

* Certification mustbe submitted.

Unit PackagingDYesDNo

If "Yes,"Unit Package wgt. No. per

container

Water Soluble PackagingDYesDNo

If "Yes,"Unit Package wgt. No. per container

2. Type of ContainerD MetalD PlasticD GlassD PaperD Other (Specify)_

3. Location of Net Contents Information

D Label D Container

4. Size(s) of Retail Container 5. Location of Label DirectionD On LabelD On Labeling accompanying product

6. Manner In Which Label Is Affixed to Product D LithographD Paper gluedD Stenciled

D Other

Section - IV

1. Contact Point (Complete items directly below for identification of individual to be contacted, if necessary, to process this application.)

NameCristina Griffin

TitleAgent for Pioneer Americas,

LLC, D/B/A Olin Chlor Alkali

Products

Telephone No. (Include Area Code)301-680-7971

CertificationI certify that the statements I have made on this form and all attachments thereto are true, accurate and complete. I acknowledge that any kindof knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law.

2. Signature

4. Typed Name

Cristina Griffin

3. TitleAgent for Pioneer Americas, LLC, D/B/A

Olin Chlor Alkali Products

5. DateApril 23, 2012

B. Date Applicationreceived

(S-.amped)

EPA Form 8570-1 (Rev. 8-94) Previous editions are obsolete. White - EPA File Copy (original) Yellow - Applicant copy

Page 3: US EPA, Pesticide Product Label, BACTI-CHLOR, 05/16/2012 · 5/16/2012  · Products / Bacti-Chlor 2. EPA Product Manager Monisha Harris PM#32 3. Proposed Classification D None D Restricted

3 J

DELTAANALYTICAL

CORPORATION

April 23, 2012

Document Processing Desk (NOTIF)Office of Pesticide Programs (7504P)Environmental Protection AgencyOne Potomac Yard2777 S. Crystal Drive, Room S-4900Arlington VA 22202

Attn: Monisha Harris, PM 32

Re: Notification under PR Notice 98-10 to add non pesticidal language and make minor labelchanges.Product: Bacti-Chlor, EPA Reg. No. 37982-38Company: Pioneer Americas, LLC, D/B/A Olin Chlor Alkali Products

Dear Monisha:

On behalf of Pioneer Americas, LLC, D/B/A Olin Chlor Alkali Products, I am submitting a notification per PRNotice 98-10 to add non pesticidal language and make minor label changes, to the label for Bacti-Chlor, EPAReg. No. 37982-38. All label changes are highlighted.

The changes are:• Deleting the wording on page 1 after establishment numbers: "See Bill of Lading for specific establishment

number," and replacing it with the master label reader's note: "[On production label, either only one est.number or the following note will appear: "Producing establishment is marked."]"

• Revising the wording on page 1 from "Net Wt: [See Bill of Lading]" to "Net Contents: Gallons" (theproduct is a liquid. Net contents will be shown on labeling rather than on bill of lading.)

• Adding minor reader's notes at the bottom of page 2 Non Ag Uses

Enclosures• EPA form 8570-1• 1 copy of the label with all changes highlighted

If you have any questions regarding this submission, please contact me at 301-680-7971 or [email protected].

Jristina Griffin ^ 'UAgent for Pioneer Americas, LLC, D/B/A Olin Chlor Alkali Products

cc: Vickie Ray, Olin Corporation

12510 Prosperity Drive Suite 160 Silver Spring, Maryland 20904(301)680-7971 fax (301) 680-7975 www.delta-ac.com

Page 4: US EPA, Pesticide Product Label, BACTI-CHLOR, 05/16/2012 · 5/16/2012  · Products / Bacti-Chlor 2. EPA Product Manager Monisha Harris PM#32 3. Proposed Classification D None D Restricted

BACTI-CHLORACTIVE INGREDIENT:Sodium Hypochlorite 11.0%OTHER INGREDIENTS 89.0%TOTAL 100.0%

KEEP OUT OF REACH OF CHILDREN

DANGERFIRST AID

Call a poison control center or doctor immediately for treatment advice. Have the product container or label with you when you call a poisoncontrol center or doctor, or when going for treatment.

If in

If on

eyes:Hold eye open and rinse slowly and gently with water for 15-20 minutes.Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye.

I Take off contaminated clothing.skin or clothing: j Rinse skin immediately with plenty of water for 1 5-20 minutes.•

If swallowed:

NOTE TO PHYSICIAN -

Have person sip a glass of water if able to swallow.Do not induce vomiting unless told to do so by the poison control center or doctor.Do not give anything by mouth to an unconscious person.

- Probable mucosal damage may contraindicate the use of gastric lavage.

FOR ALL ACCIDENTS, CALL CHEMTREC AT 1-800-424-9300 (in USA)OR NEWALTA AT 1-800-567-7455 (in CANADA)

PRECAUTIONARY STATEMENTSHAZARDS TO HUMANS AND DOMESTIC ANIMALS:

DANGER. Corrosive. May cause severe skin and eye irritation or chemical burns to broken skin. Causes eye damage. Do not get in eyes, on skin, oron clothing. Wear safety glasses or goggles and rubber gloves when handling this product. Wash after handling. Avoid breathing vapors. Vacate poorlyventilated areas as soon as possible. Do not return until strong odors have dissipated.

PERSONAL PROTECTIVE EQUIPMENT (PPE)Applicators and other handlers must wear: 1) goggles or face shield, 2) long-sleeved shirt and long pants, 3) waterproof gloves, 4) shoes plus socks.

Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions for washables, use detergent and hot water. Keep and wash PPEseparately from other laundry.

PHYSICAL OR CHEMICAL HAZARDS

Strong oxidizing agent. Use only according to label directions. Mixing this product with gross filth, such as feces, urine, etc. or with ammonia, acids,detergents, or other chemicals will release hazardous gases which are irritating to eyes, lungs and mucous membranes.

ENVIRONMENTAL HAZARDS

This pesticide is toxic to fish and aquatic organisms. Do not discharge effluent containing this product into lakes, ponds, streams, estuaries, oceans orpublic waters unless in accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit and the permitting authorityhas been notified in writing prior to discharge. Do not discharge effluent containing this product into sewer systems without previously notifying the sewagetreatment plant authority. For guidance contact your State Water Board or Regional Office of the EPA.

STORAGE AND DISPOSAL: Do not contaminate food or feed by storage, disposal or cleaning of equipment. Pesticide Storage: Store thisproduct in a cool, dry area away from direct sunlight and heat to avoid deterioration. In case of spill, flood areas with large amounts of water.Pesticide Disposal: Product or rinsates that cannot be used should be diluted with water before disposal in a sanitary sewer or other approveddisposal facility. Container: Tank Cars and Tank Trucks: Refill with bleach OR triple or pressure rinse empty tank car or tank truck to remotebleach residues before filling with other product. Drums, Totes, and Intermediate Bulk Containers (IBC): Refill with bleach only, "i n'ple or pressurerinse nonrefillable or cracked refillable containers and offer for recycling, reconditioning or disposal. Dispose of residue rinsates in a sanitary seweror other approved disposal facility.

PIONEER AMERICAS, LLCD/B/A OLIN CHLOR ALKALI PRODUCTS490 STUART ROAD N.E.CLEVELAND, TN 37312 Net Contents: Gallons

EPA Reg No.: 37982-38EPA Est No.:

72315-AL-00172315-GA-00172315-NY-00172315-TN-001

61667-CA-OM61667-CA-OC261667-LA-00161667-NV-OC1

61667-WA-00271217-CAN-0022315-AL-001

/On production label, either only one est. number or thefollowing note will appear: "Producing establishmentis marked."]

Page 5: US EPA, Pesticide Product Label, BACTI-CHLOR, 05/16/2012 · 5/16/2012  · Products / Bacti-Chlor 2. EPA Product Manager Monisha Harris PM#32 3. Proposed Classification D None D Restricted

(Bacti-chlor

Directions for UseIt is a violation of federal law to use this product in a

manner inconsistent with its labeling.

Note - This product degrades with age. Use a chlorinetest kit and increase dosage as necessary to obtain therequired level of available chlorine.

AGRICULTURAL USES

AGRICULTURAL USE REQUIREMENTUse this product only in accordance with its labeling andwith the Worker Protection Standard, 40 CFR part 170.This Standard contains requirements for the protection ofagricultural workers on farms, forests, nurseries,greenhouses, and handlers of agricultural pesticides. Itcontains requirements for training, decontamination,notification, and emergency assistance. It also containsspecific instructions and exceptions pertaining to thestatements on this label about personal protectiveequipment (PPE), and restricted-entry interval. Therequirements in this box only apply to uses of thisproduct that are covered by the Workers ProtectionStandard.

The Restricted-Entry Interval (REI) is 0 days when usingthis product.

There are no posting or notification requirements whenusing this product.

Personal Protective Equipment should be worn asdescribed under the "Precautionary Statements" sectionof this label.

DRIP IRRIGATION - This product is to be appliedthrough drip/trickle sprinkler irrigation systems only foragricultural crops and only where this manner of use willnot cause crop damage. The plugging of drip irrigationemitters is a universal problem that will cause a lack ofwater application uniformity. One of the primary causesof emitter plugging is the proliferation of bacteria andalgae within the lines and emitters of a drip irrigationsystem. Bacti-chlor is an additive that controls both algaeand bacterial growth resulting in a uniform distribution ofwater. The amount of Bacti-chlor required for injectioninto the irrigation water to supply a desired dosage in ppmcan be calculated by the following equation:

I = (0.006) (ppm desired) (system flow rate in gallons perminute) / 11

With a chlorine test kit, determine the residual chlorine atthe emitter farthest from the injection pump. The residualchlorine should be between 1.0 ppm and 2.0 ppm with awater pH of 7.2-7.6.

NOTE: This calculation, when applied to clean waterwhich is free of amine nitrogen and organic nutrients, willgive a result close to the actual product injection raterequired. In actual practice, however, contaminants in thewater may consume the product such that the availablechlorine concentration is less than expected from thecalculation. To correctly establish the product dose settingrequired, it is necessary to measure the available chlorineat the end of the treated increment in the field and adjustthe dose setting until the desired available chlorineconcentration is obtained. Only experience can establishthe actual injector settings required to provide the desiredlevel of available chlorine at the end of the farthest lateral.

Injection should be started during irrigation, near the endof the irrigation sequence, but early enough to establishthe desired available chlorine concentration throughoutthe system being treated. Apply the product upstream ofthe filter to help keep the filter clean. Allow sufficienttime to achieve a steady reading.

If the irrigation water has high levels of nutrients causingbacterial, algae, or other bio-fouling that reduces systemperformance, continuous use of this product may benecessary. The recommended level of free residualchlorine for continuous feed is 1 to 2 ppm, measured atthe end of the farthest lateral using a good quality test kitfor free chlorine (also called "free residual" or "freeavailable" chlorine).

Periodic shock treatments at a higher chlorine rate of upto 20 ppm free residual may be appropriate where bacteriaand/or algae clogging and build-up are not managed bymaintaining a continuous residual. The frequency of theshock application depends upon the frequency and extentof bio-clogging.

Bringing concentrations to as much as 100 ppm totalavailable chlorine, is recommended for reclaiming low-volume irrigation systems if clogged by algae andbacterial slimes. Deliver 100 ppm in the drip svstem andmonitor the free chlorine residual at the end of tlie farthestlateral. As soon as it is established that the free residualreading is between 10 and 20 ppm, shut the system downand leave it undisturbed for up to 24 hours. Then Push allsub-mains and laterals with fresh wate-. SodiumHypochlorite will not dissolve or remove scale orinorganic sediment fouling.DO NOT apply when fertilizers, herbicide^, andinsecticides are being injected since they will consumethe available chlorine and may produce toxir reactionproducts.

Page 1 Aguses 37982-38 Bacti-chlor.041012

Page 6: US EPA, Pesticide Product Label, BACTI-CHLOR, 05/16/2012 · 5/16/2012  · Products / Bacti-Chlor 2. EPA Product Manager Monisha Harris PM#32 3. Proposed Classification D None D Restricted

Shut down the feed as soon as the irrigation water isswitched to the next irrigation sector. Leave the treatedwater residing in the section which has been shut down.

If its source water is connected to a potable water system,the irrigation water system must contain a functionalreduced-pressure-principle back-flow prevention deviceapproved by your state Department of Health,appropriately situated to prevent contamination of thepotable water system. This device must be certifiedoperational by an agent authorized for makingcertifications by the state Department of Health.

SENSITIVE PLANT SPECIES - Certain plants,including various species of trees, flowers, shrubs,agronomic crops, fruits and vegetables are adverselyaffected by chlorinated irrigation. The use of this productcan impact the growth, appearance and health of theplants.

Begonias, geraniums and other ornamental plant speciesare known to be sensitive to continuous chlorination atlevels of 1-2 ppm free chlorine. Plant species such astomato, lettuce, broccoli, and petunia are sensitive toperiodic chlorination levels of 10-20 ppm free chlorine.

If uncertain of a plant's tolerance, consult an agronomistor a support agency such as your local UniversityExtension Service or your local agent of the USDepartment of Agriculture or use an alternate method toremove bio-fouling from the irrigation system.

CONTROLLING SEEDBORNE BAKANAEDISEASE OF RICE - To aid in surface sterilization ofrice seed for prevention of bakanae disease Fusariumfujikuroi [syn. F. moniliforme] or Gibberella fujikuroi,mix 3 gallons of this product per 110 gallons of water tomake a 3000 ppm available chlorine solution. Mixsolution thoroughly, then apply to seeds. Soak the seedsfor two hours, then drain solution and replace with freshwater. Continue seed soaking and draining as usual. Donot apply undiluted product directly to seed.

Alternatively, make a 1500 ppm available chlorinesolution by mixing 1.5 gallons of this product with 110gallons of water. Mix solution thoroughly, then apply toseeds. Soak and drain seed as usual. No rinsing isrequired. Do not apply undiluted product directly to seed.

Prepare a fresh solution for each batch of seed. Do notuse treated seeds for food or feed.

fe/l

Page 2 Aguses 37982-38 Bacti-chlor.041012

Page 7: US EPA, Pesticide Product Label, BACTI-CHLOR, 05/16/2012 · 5/16/2012  · Products / Bacti-Chlor 2. EPA Product Manager Monisha Harris PM#32 3. Proposed Classification D None D Restricted

Bacti-chlor

Directions for UseIt is a violation of federal law to use this product in a

manner inconsistent with its labeling.

Note - This product degrades with age. Use a chlorinetest kit and increase dosage as necessary to obtain therequired level of available chlorine.

[Non Agricultural Use]

SANITIZATION OF NONPOROUS FOODCONTACT SURFACES

RINSE METHOD - A solution of 100 ppm availablechlorine may be used in the sanitizing solution if achlorine test kit is available. Solutions containing aninitial concentration of 100 ppm available chlorine mustbe tested and adjusted periodically to insure that theavailable chlorine does not drop below 50 ppm. Prepare a100 ppm sanitizing solution by thoroughly mixing 1 oz. ofthis product with 8 gallons of water. If no test kit isavailable, prepare a sanitizing solution by thoroughlymixing 2 oz. of this product with 8 gallons of water toprovide approximately 200 ppm available chlorine byweight.

Clean equipment surfaces in the normal manner. Prior touse, rinse all surfaces thoroughly with the sanitizingsolution, maintaining contact with the sanitizer for at least2 minutes. If solution contains less than 50 ppm availablechlorine, as determined by a suitable test kit, eitherdiscard the solution or add sufficient product toreestablish a 200 ppm residual. Do not rinse equipmentwith water after treatment and do not soak equipmentovernight. Sanitizers used in automated systems may beused for general cleaning but may not be reused forsanitizing purposes.

IMMERSION METHOD - A solution of 100 ppmavailable chlorine may be used in the sanitizing solution ifa chlorine test kit is available. Solutions containing aninitial concentration of 100 ppm available chlorine mustbe tested and adjusted periodically to insure that theavailable chlorine does not drop below 50 ppm. Prepare a100 ppm sanitizing solution by thoroughly mixing 1 oz. ofthis product with 8 gallons of water. If no test kit isavailable, prepare a sanitizing solution by thoroughlymixing 2 oz. of this product with 8 gallons of water toprovide approximately 200 ppm available chlorine byweight.

Clean equipment in the normal manner. Prior to use,immerse equipment in the sanitizing solution for at least 2

minutes and allow the sanitizer to drain. If solutioncontains less than 50 ppm available chlorine, asdetermined by a suitable test kit, either discard thesolution or add sufficient product to reestablish a 200 ppmresidual. Do not rinse equipment with water aftertreatment.

Sanitizers used in automated systems may be used forgeneral cleaning but may not be reused for sanitizingpurposes.

FLOW/PRESSURE METHOD - Disassembleequipment and thoroughly clean after use. Assembleequipment in operating position prior to use. Prepare avolume of 200 ppm available chlorine sanitizing solutionequal to 110% of volume capacity of the equipment bymixing the product in a ratio of 2 oz. of product with 8gallons of water. Pump solution through the system untilfull flow is obtained at all extremities, the system iscompletely filled with the sanitizer and all air is removedfrom the system. Close drain valves and hold underpressure for at least 2 minutes to insure contact with allinternal surfaces. Remove some cleaning solution fromdrain valve and test with a chlorine test kit. Repeat entirecleaning/sanitizing process if effluent contains less than50 ppm available chlorine.

CLEAN-IN-PLACE METHOD - Thoroughly cleanequipment after use. Prepare a volume of a 200 ppmavailable chlorine sanitizing solution equal to 110% ofvolume capacity of the equipment by mixing the productin a ratio of 2 oz. of product with 8 gallons of water.Pump solution through the system until full flow isobtained at all extremities, the system is completely filledwith the sanitizer and all air is removed from the system.Close drain valves and hold under pressure for at least 10minutes to insure contact with all internal surfaces.Remove some cleaning solution from drain valve and testwith a chlorine test kit. Repeat entire cleaning/sanitizingprocess if effluent contains less than 50 ppm availablechlorine.

SPRAY/FOG METHOD - Pre-clean all surface afteruse. Use a 200 ppm available chlorine solution to controlbacteria, mold or fungi and a 600 ppm solution tu controlbacteriophage. Prepare a 200 ppm sanitizing solution ofsufficient size by thoroughly mixing the product in a ratioof 2 oz. product with 8 gallons of water. Prepa-'e a 600ppm solution by thoroughly mixing the product in theratio of 3 oz. product with 4 gallons of water. Use sprayor fogging equipment which can resist hypochloritesolutions. Always empty and rinse spray/fog equipment

Page 1 Non Ag uses 37982-38 Bacti-chlor 041012

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with potable water after use. Thoroughly spray or fog allsurfaces until wet allowing excess sanitizer to drain.Vacate area for at least 2 hours. Prior to using equipment,rinse all surfaces treated with a 600 ppm solution with a200 ppm solution.

CLEANING FORMULATIONS, BLEACHING, &NON-PESTICIDE CHEMICAL MANUFACTURINGThis product may be used for cleaning formulations,bleaching and non-pesticide chemical manufacturing.Only specifically designed handling and dispensingequipment should be used in accordance withmanufacturer's instructions and according to operatinginstructions or product formulations defined by the usefacility.

Pioneer Americas, LLCd/b/a Olin Chlor Alkali Products

490 Stuart Road N.E.Cleveland, TN 37312

EPA Reg. No.: 37982-38

EPA Est. No.: [On production label, either only one est. number or thefollowing note will appear: "Producing establishment is marked."]

[The following may be used on labeling to assist in tracking production labeldates:]

/ESL and/or ENL [insert date[s]]]

[Wording in brackets is instructional or optional]

F\shared\OUN\37982-38\Labels\2012\nofif label 041012, ENL 011110.doc 4/10/12

Page 2 NonAguses 37982-38 Bacti-chlor.041012


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